Yes, I would be happy to.
First, I think this committee is aware that banks provide millions of reports to FINTRAC every year. We're excited by seeing a provision that would have more output from all that input. I think what this provision is trying to address is the mens rea or the mental element to a criminal offence. It's lowering the bar from a knowledge base of the actual predicate offence to a recklessness. There are professional money launderers who try to blind themselves to what's going on underneath this, and this would allow for that mental element to be lowered so that they would still be caught. Again our view is that we're looking for more output from the system, given the amount of input that is put into the system.
The second question, I think, was about a risk-based approach. As I said, banks are fully committed to the MLTFA regime and are key partners, but they want to spend their time and resources for the highest impact for the biggest buck. And that's the highest risk customer.
There are provisions in the PCMLTFA currently that require a lot of administrative work with low-risk customers when it's ongoing monitoring, where you sort of have to refresh the ID of someone who has a term CDIC and is retired. It just feels as if there could be better ways to use that time and resources.